Drone Imaging

Owners: Lucas Denton & Andrew Denton

510 Jarrell Rd. Greenville, Ga 30222

940-655-8334

U.S. Department of Transportation Federal Aviation Administration

Oct 30, 2015

Re: Exemption request pursuant to Section 333 of the FAA Reform Act and

Part 11 of the Federal Aviation Regulations from: 14 CFR 21 subpart H; 14

CFR 45.23(b); 14 CFR 61.113(a) and (b); 14 CFR 91.7(a); 14 CFR

91.9(b)(2); 14 CFR 91.109; 14 CFR 91.119(C); 14 CFR 91.121; 14 CFR

91.151(a); 14 CFR 91.203(a) and (b); 14 CFR 91.405(a); 14 CFR

91.407(a)(1); 14 CFR 91.409(a)(1) and (2); 14 CFR 91.417(a) and (b)

Dear Sir or Madam,

Pursuant to Section 333 of the Federal Aviation Administration (FAA)

Modernization and Reform Act of 2012 (the “Reform Act”) and 14 CFR Part

11, Lucas Denton, owner of Drone Imaging (Drone Imaging) which owns

and operates an Unmanned Aircraft System (UAS), hereby applies for an

exemption from the listed Federal Aviation Regulations (FARs) to allow

commercial operation of its UAS, so long as such operations are conducted

within and under the conditions outlined herein or as may be established by

the FAA as required by Section 333.

Commercial operation of an UAS, as described herein, which are equipped

with camera(s) and sensors, would operate in the following manner:

- Aerial photography and/or video for public and/or private use

including real estate, architecture, surveying, engineering and other

related professional activities.

- Aerial video and/or photography for public and/or private use

including television, public events, private events, cinematography and
news gathering.

- Aerial inspection/photography of residential/commercial structures

under contract with the owners or local government authority.

- Aerial inspection/photography or residential/commercial utility

infrastructure including but not limited to electrical power lines, wind

turbines and cell towers.

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- Aerial video/photography or providing live video feed to assist with search

and rescue operations in cases of emergency or natural disaster only when the

local authorities or government has requested it by contract or donation.

Drone Imaging operates one Yuneec Q5004k (4) blade quad copter weighing

3.75 pounds, 1700grams (see attached manual). The UAS has a maximum

airspeed of 18 miles per hour and uses a remote controller operating on

frequency range of 2.400-2.483 GHZ. The Yuneec Q500 4k is equipped with

built-in ground support technology that allows it to fly utilizing global

positioning system (GPS) for stability, tracking, safe flight mode and a

return-to-home feature in the event of loss of remote control signal or critical

low battery. All flights start with a pre-flight safety check and all flight data

are recorded. The Yuneec Q500 4k is equipped with a gimbal mounted

camera that sends a live video signal to the controller allowing the person in

control (PIC) to monitor real-time video. Flight data, speed height, distance,

battery level and general aircraft conditions are also displayed during

operation. The Yuneec Q500 4k battery has a flight time of 25 minutes and

is, therefore, always returned to original takeoff point and always flown

utilizing visual line of sight (VLOS). We have been training on the Yuneec

Q500 4k for seven months and have become proficient in all aspects of flight

and safety of this UAS. Our request for exemption would allow us to offer

unique aerial photography and videography services to our clientele.

UAS Safety Operating Parameters
We will abide by the following additional operating conditions under this

exemption, which ensures a level of safety during UAS flight including

operating the UAS below 400 feed and within a radius of 1,000 feet from PIC

always maintaining VLOS and obtaining permission from the

owner/controller of any vessels, vehicles and structures when operations may

be conducted closer than 500 feet to any such vessels, vehicles or structures.

We will conduct a safety assessment of the risk of operating closer to those

objects and determine that it does not present an undue hazard. Other safety

operating parameters include:

- Operate the UAS for 15-20 minutes per flight.

- Land UAS prior to the manufacturers recommended minimum level

of battery power.

- Operate the UAS during daylight hours only within VLOS.

- Utilize the UAS’ GPS flight safety feature whereby it hovers and

then slowly lands if

communication with the PIC is lost or battery becomes critically low.

- Always obtain all necessary permissions prior to operation.

- Have procedures in place to abort flights in the event of safety

breaches or potential danger.

- Review weather reports prior to flight and never operate UAS in

unsafe conditions, high wind,

low clouds or conditions that hinder visibility.

- Only operate in safe environments that are strictly controlled, are

away from power lines,
elevated lights, airports and densely populated areas.

- Also conduct extensive preflight inspections and protocols during

which safety carries primary

importance.

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The PIC will also have a minimum of five hours logged on this craft and 10

hours minimum flying UAS quad copters under varying conditions and

environments and will follow all safety protocol of Drone Imaging as well as

guidelines of 14 CFR §61.51(b) having the ability to safely operate the UAS

in a manner consistent with the operating documents, including evasive and

emergency maneuvers and maintaining appropriate distances from people.

Specific Exemptions Requested

Given the size, weight, speed and limited operating area associated with the

UAS, we feel an exemption from 14 CFR Part 21, Subpart H (Airworthiness

Certificates) and 14 CFR 91.203(a) and (b) (certifications required), subject

to certain conditions and limitations, is warranted and meets the requirements

for an equivalent level of safety under 14 CFR Part 11 and Section 333 of

P.L. 112-95 (Section 333).

We request an exemption from 14 CFR 45.23 Marking of the Aircraft

because the UAS will not have a cabin, cockpit or pilot station on which to

mark certain words or phrases. Further, the two-inch lettering is difficult to

place on such a small aircraft with dimensions smaller than the minimal

lettering requirement. Regardless of this, we can mark the UAS in the largest

possible lettering by placing the word “Experimental” on its fuselage as

required by 14 CFR 45.29(f) so that anyone will see the markings.

We request an exemption from 14 CFR 61.113(a) and (b) Private Pilot

Privileges and Limitations: Pilot in Command. The applicant’s UAS do not

carry any pilots or passengers nor property. The Risks attendant to the

operation of the UAS is far less than the risk levels inherent in the

commercial activities outlined in 14 CFR §61. The operation and limitations
in the flight operation manual (FOM) will equate to the safe operations of the

UAS.

We request an exemption from 14 CFR 91.7(a) which prohibits the operation

of an aircraft without an airworthiness certificate, since there is currently no

certificate applicable to our operation, this regulation is inapplicable. We

request an exemption from 14 CFR 91.405(a), 14 CFR 91.407(a)(1), 14 CFR

91.409(a)2) and 14 CFR 91.417(a) and (b) Maintenance inspections since

they only apply to aircraft with an airworthiness certificate. However, as a

safety precaution, we will perform a preflight inspection of the UAS before

each flight as outlined in the attached operating documents.

We request an exemption from 14 CFR 91.9(b)(2) which requires an aircraft

FOM in the aircraft, however, since there are no pilots or passengers on board

the aircraft, and given its size, this regulation is inapplicable. We believe an

equivalent level of safety will be achieved by maintaining a safety/flight

manual with the UAS ground station.

We request an exemption from 14 CFR 91.109 Flight Instruction: Simulated

Instrument Flight and Certain Flight Tests. The regulation states that “no

person may operate a civil aircraft that is being used for flight instruction

unless that aircraft has fully functioning dual controls. Although the Yuneec

Q500 4K is capable of dual/linked controls, we will be operating with a

single remote controller.

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We request an exemption from 14 CFR 91.119(c) which prescribes safe

altitudes for the operation of civil aircraft, but allows helicopters to be

operated at lower altitudes in certain conditions. We will not operate our

UAS above the altitude of 400 feet above ground level (AGL) and will also

only operate in safe areas away from the public and traffic, thus “providing a

level of safety at least equivalent to or below those in relation to minimum

safe altitudes.” Given the size, weight and maneuverability and speed of the

UAS, an equivalent or higher level of safety will be achieved.

We request an exemption from 14 CFR 91.121 Altimeter Settings, as it is

inapplicable since the UAS utilizes electronic GPS with a barometric sensor.

We request an exemption from 14 CFR 91.151(a) Fuel Requirements for
Flight in visual flight rules (VFR) conditions. The UAS is 100 percent

electric and two low battery alerts are issued – per the operating documents,

the UAS will be landed at the first alert. Also, our flights will last only 15-20

minutes each and the UAS has an automated function, which results in

immediate landing when a low battery is detected. The PIC will not begin a

flight unless, considering wind an forecast weather conditions, there is

enough power to fly to the first point of intended landing and, assuming

normal cruising speed, land the UAS with 30 percent battery power

remaining.

Summary

We will comply with all of the following conditions and limitations should

this grant of exemption be provided:

1. Operations will be limited to the following aircraft described in the

operating documents which is a quad-rotor aircraft weighing less than

seven pounds: Yuneec Q500 4K Aircraft System.

2. The UAS will not be flown at an indicated airspeed exceeding 40 mph.

3. The UAS will be operated at an altitude of no more than 400 feet AGL,

as indicated by the

procedures specified in the operating documents.

4. The UAS will be operated within VLOS of the PIC at all times.

5. All operations may utilize a visual observer (VO. The UAS will be

operated within the VLOS of the

VO at all times. The VO and PIC will be able to communicate verbally

at all times. The PIC will be designated before the flight and will not

transfer his or her designation for the duration of the flight. The PIC

will ensure that the VO can perform the functions prescribed in the

operating documents.
6. The operating documents will be accessible during the UAS operations

and made available to the Administrator upon request. Any revisions to

the operating documents will be presented to the Administrator upon

request.

7. Prior to each flight, the PIC will inspect the UAS to ensure it is in a

condition for safe flight. If the inspection reveals a condition that

affects the safe operation of the UAS, the UAS will not be operated

until the necessary maintenance has been performed and the UAS is

found to be in a condition for safe flight. The Ground Control Station

will be included in the preflight inspection. All maintenance and

alterations will be properly documents in the aircraft records.

8. Any UAS maintenance or alterations that affect the UAS operation or

flight characteristics, e.g. replacement of a flight critical component,

will undergo a functional test flight. The PIC who conducts the

functional test flight will make an entry into the aircraft records.

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9. The pre-flight inspection section in the operating documents will

account for all discrepancies, i.e. inoperable components, items or

equipment not already covered in the relevant sections of the operating

documents.

10. We will follow the UAS manufacturer’s aircraft/component,

maintenance, overhaul, replacement, inspection and life limit

requirements.

11. We will carry out maintenance, inspections and record-keeping

requirements, in accordance with the operating documents.

Maintenance, inspection and alterations will be noted in the aircraft

records, including total flight hours, description of work accomplished
and the signature of the authorized person returning the UAS to service.

12. Each UAS operated will comply with all manufacturer Safety Bulletins.

13. An authorized person will make an entry in the aircraft record of the

corrective action taken

against discrepancies discovered between inspections.

14. The PIC will also meet the flight review requirements specified in 14

CFR 61.56 in an aircraft in

which the PIC is rated on.

15. Prior to operations conducted for the purpose of aerial

videography/cinematography and

augmenting real estate listing videos (or similar operations), the PIC

will have accumulated and logged, in a manner consistent with 14 CFR

61.51(b), a minimum of five hours as an UAS pilot operating the make

and model of the UAS to be used in operations.

16. The PIC will not operate the UAS for the purpose of aerial

videography/cinematography and augmenting real estate listing videos

(or similar operations), unless the PIC has demonstrated and logged in

a manner consistent with 14 CFR 61.51(b), the ability to safely operate

the UAS in a manner consistent with the operating documents,

including evasive and emergency maneuvers and maintaining

appropriate distances from people, vessels, vehicles and structures.

17. UAS operations will not be conducted during night hours, as defined in

14 CFR 1.1 All operations will be conducted under visual

meteorological conditions (VMC).
18. The UAS will not operate within five nautical miles of an airport

reference point as denoted on a current FAA-published aeronautical

chart.

19. The UAS will not be operated less than 500 feet below or less than

2,000 feet horizontally from a cloud or when visibility is less than three

statute miles from the PIC.

20. If a UAS loses communications or loses its GPS signal, it will return to

a predetermined location within the planned operating area and land or

be recovered in accordance with the operating documents.

21. The PIC will abort a flight in the event of unpredicted obstacles or

emergencies in accordance with the operating documents.

22. The PIC will not begin a flight unless, considering wind and forecast

weather conditions, there is enough power to fly at a normal cruising

speed to the intended landing point and land the UAS with 30 percent

battery power remaining.

23. Before conducting operations, the radio frequency spectrum used for

operation and control of the UAS will comply with the Federal

Communications Commission (FCC) or other appropriate government

oversight agency requirements.

24. The documents required under 14 CFR 91.9 and 14 CFR 91.203 would

be available to the PIC at the Ground Control Station of the UAS at any

time the UAS is operating. These documents will be made available to

the Administrator or any law enforcement official upon request.

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25. The UAS will remain clear and yield the right of way to all manned

aviation operations and activities at all times.

26. The UAS will not be operated by the PIC from any moving device or

vehicle.

27. The UAS will not be operated over congested or densely populated

areas unless contracted out

to do events.

28. Flight operations will be conducted at least 500 feet from all

nonparticipating persons, vessels,

vehicles and structures unless:

a. Barriers or structures are present that sufficiently protect

nonparticipating persons from

the UAS and/or debris in the event of an accident. We will ensure

that nonparticipating persons remain under such protection. If a

situation arises where nonparticipating persons leave such

protection and are within 500 feet of the UAS, flight operations

must cease immediately.

b. The aircraft is operated near vessels, vehicles or structures where

the owner/controller of such vessels, vehicles or structures has

granted permission and the PIC has made a safety assessment of

the risk of operating closer to those objects and determined that it

does not present an undue hazard.

c. Operations near to the PIC, VO, operator trainees or essential

persons do not present an undue hazard to those persons per 14

CFR 91.119(a).
29. All operations will be conducted over private or controlled-access

property with permission from the land owner/controller or authorized

representative. Permission from land owner/controller or authorized

representative will be obtained for each flight to be conducted.

30. Any incident, accident or flight operation that transgresses the lateral or

vertical boundaries of the operational area as defined by the applicable

certificate of authorization (COA) will be reported to the FAA’s UAS

Integration Office (AFS-80) within 24 hours. Accidents will be

reported to the National Transportation Safety Board (NTSB) per

instructions contained on the NTSB website: www.ntsb.gov.

On behalf ofDrone Imaging, I would like to thank you for your consideration

in granting this exemption.

Signed,

Lucas Denton

Drone Imaging